December 2021

Bulk hydroflurocarbons (HFC’s)require 14 days advance reporting to EPA beginning January 1

Under the American Innovation and Manufacturing Act of 2020, EPA will require 14 days advance reporting prior to releasing bulk HFC imports. This is VERY problematic for air, rail, and truck shipments, and ocean shipments of less than 14 days transit.  They have also set up an “allowance” program that must be met for importations as well.  This is a complicated program that importers of HFC’s must be familiar with.  For basic information, please go to

Mangus confirmed by Senate as CBP Commissioner (From Sandler Travis and Rosenberg)

The Senate voted Dec. 7 to confirm Tucson, Ariz., police chief Chris Magnus as commissioner of U.S. Customs and Border Protection. Magnus previously served as police chief in the cities of Fargo, N.D., and Richmond, Calif., after rising through the ranks of the Lansing, Mich., police department.

Ed. note: We expect little or no change in CBP policies under Mr. Magnus.

Cybercrime increasing significantly (From Roanoke Insurance)

The spread of the COVID-19 virus combined with disruptive measures enacted by governments worldwide has inspired criminals to adopt alternative, and unfortunately, successful tactics. Increasingly, thieves target facilities over trucks, and a spike in the theft of PPE and related medical goods last year exemplifies the use of these new methods.

Another concerning trend developing over the past year and a half is the rampant use of fraud by cargo thieves. Fraud is not a new phenomenon; however, when combined with cyber-crime, it is a tactic that presents a complex security risk for organizations to manage. In addition, determining the true identity and legitimacy of parties who present themselves as business partners is becoming more difficult.

Fortunately, cybercrime insurance is now widely available. In fact, we just renewed our policy.  We suggest that you contact your commercial insurance agent to investigate if it is appropriate for your company.  We will be glad to refer you to our agent if yours does not offer this coverage.

We all wish you a very merry Christmas and a prosperous New Year!